Proposed Section 751(b) Regulations: An ‘Exchange’ for the Better?

123 J. TAX'N 52 (2015)

35 Pages Posted: 1 Jul 2017

See all articles by Douglas L. Longhofer

Douglas L. Longhofer

University of Central Missouri

Bryan A Rimmke

Ernst & Young LLP - Washington, D.C. Office

Date Written: May 29, 2015

Abstract

In 2014, Treasury and the IRS issued proposed regulations concerning so-called disproportionate distributions under section 751(b). The proposed regulations adopt many of the principles first announced in Notice 2006-14 — responses to which were “predominantly favorable” according to the Preamble of the proposed regulations. This article provides a technical overview of the proposed regulations and concludes by considering whether an exchange of the current regulations for the proposed regulations achieves Treasury and the Service’s goal of writing regulations that advance the purpose of the statute while enhancing simplicity for taxpayers.

Keywords: Section 751(b), Partnership Distributions, Proposed Regulations

Suggested Citation

Longhofer, Douglas L. and Rimmke, Bryan A, Proposed Section 751(b) Regulations: An ‘Exchange’ for the Better? (May 29, 2015). 123 J. TAX'N 52 (2015), Available at SSRN: https://ssrn.com/abstract=2994912

Douglas L. Longhofer (Contact Author)

University of Central Missouri ( email )

Warrensburg, MO 64093-5070
United States

Bryan A Rimmke

Ernst & Young LLP - Washington, D.C. Office ( email )

1225 Connecticut Avenue NW
Washington, DC 20036
United States

Here is the Coronavirus
related research on SSRN

Paper statistics

Downloads
46
Abstract Views
854
PlumX Metrics